A WORD FROM THE CHAIRMAN

Transcription

1 CRB Newsletter Published by The Ohio Board of Motor Vehicle Collision Repair Winter 2010 Board Members Chairman Paul N. uncan Boardman Vice Chair Jennifer L. Haley Ameila Eric A. Poklar Powell Ronald A. Nagy Wooster Richard P. Finney Cadiz Russell Westfall Cadiz Brian K. Seibert, Sr. Vandalia Board Office Staff Executive irector Michael R. Greene A WOR FROM THE CHAIRMAN Let me extend a Happy New Year to each and everyone! We re all hoping 2010 will bring us in a new direction for Ohio s economy and the auto repair industry. As some of you learned, the CRB investigator, an Gibson, has been involved in several very successful joint agency efforts. an has worked with local zoning and fire inspectors, local law enforcement officials, EPA investigators and BMV investigators. In some areas, these agencies have teamed up to inspect auto repair shops, finding and enforcing numerous violations. These efforts, and the building of rapport between entities have opened up a whole new way of stopping illegal shops and leveling the playing field in the industry. As always, I would like to extend an invitation for all the shop owners to attend a Board meeting this year if you can break free. The meetings are open to the public and there is time set aside at each meeting for public comment. You can view meeting agendas and minutes on our website. The times and locations are posted also with a link to Map Quest for easy directions. We ll look forward to seeing you there! Please keep in touch with the staff and contact them should you have any questions. MISSION STATEMENT Paul N. uncan, Jr. Board Chairman Effectively and efficiently enforce Ohio laws by implementing Turnaround Ohio initiatives to enhance consumer protection and promote industry growth and compliance. Investigator aniel Gibson Assistant Attorney General Theodore L. Klecker, Esq. Administrative Assistant Kimberly. Sherfield 77 South High St., 16th Flr INSIE THIS ISSUE A Word From the Chairman.....Cover Investigator s Report Legislative Update irector s Letter E.P.A. National Emissions Standards Effective January 10, Columbus Oh (614)

2 INVESTIGATOR S REPORT The following is a 2009 year-end recap of activities: Complaints Investigated 157 (involving 165 shops) Notices of Violation Issued 185 New Shop Applications Issued 71 Renewal Reminders Issued 26 Prosecution Proceedings Initiated 333 Shops Located Out of Business 52 Total Shop Visits 732 LEGISLATIVE UPATE Shop owners must get involved with pending legislation if they intend on making a positive impact on our industry. Contact your local lawmakers. Each year there are numerous issues that arise. Many of these issues have an effect on the small businessperson. Shops frequently phone our office and want to know what they can do to improve problems plaguing the industry. If you contact your legislators, and have your regular patrons do the same, you can make a difference. Let them know where you stand on the issues. And let them know you are tracking their votes on legislation through the process. Nothing new to report thus far Scam Alerts Please keep in mind all the recent scams that have been popping up in the auto repair business. If you become a victim, or someone tries to make you a victim of a scam, send us the information and we ll make sure everyone gets the word. Also, you can contact Karen Gasper of the Ohio Attorney General s Office at (614) Ms. Gasper can direct you on the best steps to take if you become a victim of a scam or fraud. irector Greene 2

3 irector s Comments Happy New Year everyone! As most of you already are aware of, we moved our office to the 16 th floor of the Vern Riffe Center a few weeks ago. The move was a small part of the plan to save money for Ohio tax payers by placing all State agencies inside State owned buildings. For the Collision Board, this was a very positive move. We will save money on our office lease, yet we gained square footage. With the FY10 budget cuts, it s a lifesaver. There are several other ways our Board has managed to save money. The Board voted to reduce meetings from six each year to four, the minimum required by law. We also suspended overnight travel and out-of-state travel. We eliminated our temporary office help position, our state cellular telephone, and internet air card. We suspended all outside training and seminars. All of these cuts, along with the mandatory furlough days, pay freezes, and reductions in mileage reimbursement have assisted us in meeting our goals for But the one thing we did not touch is customer service. While many Boards found they were laying off personnel and pulling their investigators from the field, we have been able to maintain the same level of service. Our investigator will remain on the road following up on complaints and non-compliant repairers. Our mission will not suffer from the current state of this economy as long as I have anything to say about it. As I mentioned in our last newsletter, in October we started prosecution of eighteen illegal repair shops in five counties. Two of those counties, Jefferson and Belmont, are approaching court hearings in the very near future. Seven of the eighteen original shops have gotten legal. I still have to give much of the credit of our success to Ohio Attorney General Richard Cordray s staff. Without their support, we would have a very tough time doing what we do. I will keep you all updated on our progress. I hope to see some of you at one of the 2010 Board meetings. Should you have any questions, please feel free to contact my office. Michael R. Greene Executive irector 3

4 E.P.A. NATIONAL EMISSIONS STANARS EFFECTIVE JANUARY 10, 2011 The following four publications explain the emissions standards which will become effective for all existing collision repair facilities on January 10, These standards already apply to all new collision repair facilities as of January 9, Should you have questions regarding the E.P.A. National Emissions Standards, you may contact your local E.P.A office, the E.P.A. Region V office at 77 West Jackson Blvd., Chicago, IL , (312) , (312) , or (312) Or check the website at Newsletter prepared by The Ohio Board of Motor Vehicle Collision Repair 77 South High Street, 16th Floor Columbus, Ohio Phone: (614) Facsimile: (614) Website: 4

5 What Is The Compliance ate? Existing Sources: January 10, New Sources: Upon startup after January 9, An affected source is a new source if you commenced construction of the source after September 17, 2007 by installing new paint stripping or surface coating equipment at a source not actively engaged in paint stripping and/or miscellaneous surface coating prior to September 17, An affected source is an existing source if it is not a new source or a reconstructed source (An affected source is reconstructed if it meets the definition of reconstruction in section 63.2.). What are the Permitting Requirements? Affected facilities are exempt from Title V permit requirements provided they are not required to obtain a permit for another reason. What Reporting1Recordkeeping is Required? Reporting: Initial Notification (informs EPA that the facility is subject to the standards and when the source will be in compliance). New Sources: July 7, 2008 or 180 days after startup Existing Sources: January 11, 2010 Notification of Compliance (certifies that the source is in compliance with the applicable requirements). New Sources: As part of the Initial Notification Existing Sources: March 11, 2011 Annual notification of changes report required each calendar year any reportable changes occur. Recordkeeping (keep these records on file) Records to include copies of Notifications submitted to EPA. Painter training certifications. Spray booth filter efficiency documentation. Spray gun transfer efficiency. MeCI content information such as MSS. Annual usage of MeCI for paint stripping, and written MeCI minimization plan if annual usage > 1 ton per year. eviation and corrective action documentation. Records to be maintained in a form suitable and readily available for expeditious review. You can also contact your Regional EPA air toxics office at the following numbers: Websitel Address States Phone Number Region 1 CT, MA, 1 Congress Street ME, NH, (888) Suite 1100 RI, VT (617) Boston, MA Region Broadway New York, NY Region Arch Street Philadelphia, PA Region 4 Atlanta Federal Center 61 Forsyth Street, SW Atlanta, GA NJ, NY, PR, VI (212) E, M, PA, VA, (800) WV, C (215) FL, NC, SC, KY TN, GA, AL, MS Region 5 IL, IN, 77 West Jackson Blvd. MI, WI, Chicago, IL MN, OH (404) (800) (312) (312) (312) Region 6 AR, LA, Ross Avenue NM, OK, (800) * Suite 1200 TX (214) allas, TX Region North Fifth Street Kansas City, KS IA, KS, MO, NE (800) (913) Region 8 CO, MT, Wynkoop St. N, S, (800) * enver, CO UT, WY (303) Region 9 75 Hawthorne Street San Francisco, CA Region /h Ave. Suite 900, AWT-107 Seattle, WA * For sources within the region only. CA, AZ, HI, NV, GU, AS, MP (415) AK, I WA, OR For More Information (800) * (206) Copies of the rule and other materials are located at: For more information on state requirements, please contact your state representative found at the following link: United States March 2008 Environmental Protection Agency Office of Air Quality Planning & Standards (El 43-02) Summary of Regulations Controlling Air Emissions from PAINT STRIPPING AN MISCELLANEOUS SURFACE COATING OPERATIONS NATIONAL EMISSION STANARS FOR HAZAROUS AIR POLLUTANTS NESHAP (SUBPART HHHHHH) FINAL RULE

6 PAINT STRIPPING AN MISCELLANEOUS SURFACE COATING OPERATIONS (SUBPART HHHHHH) What Is an Area Source? Any source that is not a major source. (A major source is a facility that emits, or has the potential to emit in the absence of controls, at least 10 tons per year (TPY) of individual hazardous air pollutants (HAP) or 25 TPY of - combined HAP.) Who oes This Rule Apply To? Area sources that engage in any of the following: > Paint stripping operations that use methylene chloride (MeCI)-containing paint stripping formulations; Spray application of coatings to motor vehicles and mobile equipment; Spray application of coatings to a plastic and/or metal substrate where the coatings contain compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd). This rule does not apply to: Surface coating or paint stripping performed on site at installations owned or operated by the Armed Forces of the United States. Surface coating or paint stripping of military munitions or equipment directly and exclusively used for the purposes of transporting military munitions. Surface coating or paint stripping performed by individuals on their personal vehicles, property or possessions, either as a hobby or for maintenance of their personal vehicles, possessions, or property provided they coat no more than two vehicles per year. Surface coating or paint stripping that meets the definition of "research and laboratory activities." Surface coating or paint stripping that meets the definition of "quality control activities." Surface coating or paint stripping that meets the definition of "quality control activities." Surface coating or paint stripping activities that are covered under another area source NESHAP Motor vehicle or mobile equipment surface coating operations may petition the Administrator for an exemption from this subpart if you can demonstrate, to the satisfaction of the Administrator, that you spray apply no coatings that contain compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd). What Am I Required To o? Paint Stripping Operations implement management practices that minimize emissions of MeCI. > Evaluate the need for paint stripping (e.g., is it possible to re-coat without stripping?). Evaluate each application to identify potential alternative stripping methods. Reduce exposure of strippers to air. > Optimize application conditions. > Practice proper storage and disposal. For each paint stripping operation with > 1 ton MeCI annual usage, develop and implement a written MeCI minimization plan. No implementation plan is needed if usage is < 1 ton MeCI; however, sources must still utilize work practices to minimize emissions of MeCI. Consult the MSS sheet to identify the amount of MeCI contained in the paint stripper, but note that annual usage should not exceed 181 gallons of MeCI. Maintain records of annual usage of paint strippers containing MeCI. Motor Vehicle/Mobile Eguipment/Miscellaneous Surface Coating Operations. Train/certify all painters on spray gun equipment selection, spray techniques, maintenance, and environmental compliance (consult 73 FR 1738, pg. 1762, section (f)(2)(i)-(iv)). > Install/operate filter technology on all spray booths/stations/enclosures to achieve at least 98% capture efficiency. Spray booths/stations used to refinish complete motor vehicles or mobile equipment must be fully enclosed and ventilated at negative pressure or up to 0.05 inches water gauge positive pressure for booths that have seals on all doors and other openings and an automatic pressure balancing system. Spray booths/stations used to coat miscellaneous parts or products or vehicle subassemblies must have a full roof, at least three complete walls or side curtains, and ventilated so that air is drawn into the booth. Spray-applied coatings must be applied with a high volume, low pressure (HVLP) spray gun, electrostatic application, airless or air-assisted airless spray gun, or an equivalent technology. > Paint spray gun cleaning must be done so that an atomized mist or spray of the cleaning solvent is not created outside a container that collects used gun cleaning solvent. Train and certify all personnel who spray apply surface coatings no later than 180 days after hiring or by July 7, 2008 (new sources) or by January 10, 2011 (existing sources). What are the Impacts? Most paint stripping facilities already comply with the rule requirements. Estimate 1,000 facilities will need to take action to comply. Reduce 1,000 tons MeCI annually, Capital costs = $1.5 million. > Annual benefit = $0.9 million. Most surface coating facilities already comply with the rule requirements. Estimate < 25% of existing facilities will need to take some action to comply. Reduce 6,900 tons of HAP annually including 11 tons of metal HAP. Capital costs = $20 million; however, initial cost to be offset and recovered over time by cost savings as a result of more efficient use of labor and materials.

7 *ay " EPA United States Environmental Protection Agency esign for the Environment, Auto Refinishing Shop Project EPA 744-F November 1999, Revised June 2000 BEST PRACTICES FOR AUTO REFINISHERS WHEN SPRA 17PAINTING SAVE $$$$$ ON PAINT I REUCE EMISSIONS FROM YOUR SHOP 'KEEP YOUR PAINTERS AN TECHNICIANS SAFE AN HEALTHY I q SPRAY PAINT IN A WELL-VENTILATE SPRAY BOOTH For painters-a well-ventilated and maintained spray booth efficiently removes paint overspray from the air, minimizing contact with hazardous coating materials. For the environment-regular filter changes reduce releases of pollutants from the shop. For business-a controlled flow of dust-free air improves the quality of the paint job. Among spray booths downdraft, semi-down, and crossdraft a downdraft is the most effective at removing hazardous overspray. v Remember: It is always better to spray inside a booth or prep station than in an open bay. q USE HIGH-VOLUME, LOW- PRESSURE (HVLP) SPRAY GUNS When operated correctly, HVLP spray guns have notably higher transfer efficiencies (60-70%) than conventional spray guns (20-30%). The result: with HVLP spray guns, more paint ends up on the car and less is lost as overspray. This efficiency is a great benefit to painters, who have less contact with toxic paint components and the shop, which saves many dollars in paint costs. q WEAR AIR SUPPLIE RESPIRATORS AN CHEMICAL-RESISTANT GLOVES AN CLOTHING v By using a supplied-air, positive-pressure respirator, painters are much less likely to breathe harmful chemicals in paint spray. Most paint manufacturers say a supplied-air respirator is a "must" when spraying highly toxic materials like isocyanates, the hardener in polyurethane clearcoats and in many primers. An air-purifying respirator will not provide adequate protection unless you develop and implement a proper filter change -out schedule, which can be a complex process. v Chemical resistant gloves and paint suits help prevent skin contact with harmful paint materials. Select gloves and clothing that offer protection from the variety of chemicals in paints and coatings. For gloves, nitrile or butyl rubber make the grade, latex does not. q PUT SOMEONE IN CHARGE OF HEALTH AN SAFETY The shop manager or owner should review material safety data sheets (MSSs), and communicate chemical hazards and health and safety practices to workers. Once aware of shop hazards, workers are more likely to take precautions, stay healthy, and stay on the job! q For More Information on Best Spray Painting Practices... Talk to Mary Cushmac ( , cushmac.mary@epa.gov ) or avid ifiore ( , difiore.davidepa.gov) of the fe Project Team. THE ESIGN FOR THE ENVIRONMENT AUTO REFINISHING SHOP PROJECT'S GOAL IS TO WORK WITH AUTO REFINISHERS TO IENTIFY AN AOPT SAFER, CLEANER, MORE EFFICIENT PRACTICES AN TECHNOLOGIES.

8 Paint Stripping and Miscellaneous Surface Coating Area Source Rule Subpart HHHHHH This is not an official EPA document. This Fact Sheet is a summary of the rule for your convenience; all official determinations must be made based upon the actual final rule text See 40 CFR Headquarters Contacts: Collision Repair Campaign: Holly Wilson, , Wilson.hollya,epa.gov Paint Stripping: Warren Johnson, , Johnson.warren@epa.gov Surface Coating: Kim Teal, , teal.kimepa.gov Office of Enforcement and Compliance Assurance: Len Lazarus, , lazarus.len@epa.gov Compliance Timeline Action Required By Existing Sources New Sources (start up after 9/17/07 but before 1/9/08) New Sources (Where startup is on or after January 9, 2008) Effective ate All January 9, 2008 January 9, 2008 January 9, 2008 Compliance ate All January 10, 2011 January 9, 2008 ate of initial startup Complete Surface Coating Training Autobody and Miscellaneous Surface Coaters January 10, 2011, for existing painters, or 180 days after hiring which ever is later July 7, 2008, for existing painters, or 180 days after hiring for new hires July 7, 2008, for existing painters, or 180 days after hiring for new hires Submit Initial Notification see (a) All January 11, 2010 July 7, days after initial startup Submit Notification of Compliance Status see (b) All Notify as part of the initial notification or by March 11, 2011 Notify as part of the initial notification, by July 7, 2008 Notify as part of the initial notification, 180 days after initial startup Submit Annual Notification of Changes Report see (a) Submit a report each calendar year in which information has changed. eviations from requirements will be deemed to be a change. ue no later than March 1 of the following calendar year ue no later than March 1 of the following calendar year ue no later than March 1 of the following calendar year

9 INFORMATION NEEE FOR INITIAL NOTIFICATION Paint Stripping and Miscellaneous Surface Coating Area Source Rule (last updated March 26, 2008) Subpart HHHHHH 40 CFR [This example format may be used to meet the Initial Notification requirements of Subpart HHHHHH; however, you are not required to use this format as long as you provide the information required by 40 CFR Section (a).] 1. Company Name (if applicable) 2. Information about the owner and operator: a. Owner's Name and Title Owner's Street Address Street City State Zip Owner's telephone number Owner's (if available) Is the Operator the same person as the Owner? Yes q No q If the Operator information is different please provide the following (Attach a list with the same information for additional operators): b. Operator's Name and Title Operator's Street Address Street City State Zip Operator's telephone number Operator's (if available) Is there any other certifying company official that will sign this form?yes No If Certifying Official information is different please provide the following: c. Certifying Official's Name and Title Certifying Official's Street Address Street City State Zip Certifying Official's telephone number Certifying Official's (if available) 3. The street address (physical location) of the affected source Street City State Zip Are the compliance records located at the same location? Yes q No q If the location of compliance records if different please provide street address: Street City State Zip Is the source a motor vehicle or mobile equipment surface coating operation that repairs vehicles at the customer's location, rather than at a fixed location? Yes q No q 4. Identification of Standard (you must check this box): q Yes, I am subject to 40 CFR Part 63 Subpart HHHHHH, National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Source; Final Rule

10 5. A brief description of the type of operation: For Surface Coating Operations a. I am a: q Motor Vehicle or Mobile Equipment Surface Coating Operation q Miscellaneous Surface Coating Operation b. Number of spray booths c. Number of preparation stations d. Number of painters usually employed For Paint Stripping Operations a. Methods of paint stripping employed (check all that apply) q Chemical q Mechanical q Other (please describe) b. Substrates stripped (check all that apply) q Wood q Plastic q Metal q Other (please describe) 6. Methylene Chloride (MeCI) Used by Paint Stripping Operations o you plan to use more than 1 ton of MeCI annually? Yes q No 7 Compliance Status, please check one: For paint stripping operations, the relevant requirements that you must evaluate in making this determination are specified in 40 CFR (a) through (d) of this subpart. For surface coating operations, the relevant requirements are specified in 40 CFR (e) through (g) of this subpart. q I am already in compliance with each of the relevant requirements q I will be in compliance with each of the relevant requirements by the compliance date New Source (after Jan 9, 2008) Compliance date is date of startup New Source (after September 17, 2007 but before January 9, 2008) Compliance date is January 9, 2008 Existing source (before September 17, 2007) Compliance date is January 10, Certification of compliance status You must check one: Note: Initial startup is the first time equipment is brought online in a paint stripping or surface coating operation, and paint stripping or surface coating is first performed. I=1 I am a new source (Initial startup was on or after January 9, 2008) ate q I am a new source (Initial startup was after September 17, 2007 but before January 9, 2008) ate If your source is a new source, a responsible official, whose information is provided above, must certify by signing below that the source is in compliance with each of the relevant requirements of this subpart. q I am an existing source (Initial startup was before September 17, 2007) ate If your source is an existing source, a responsible official, whose information is provided above, may certify below that the source is already in compliance with each of the relevant requirements of this subpart or certification may be done by March 11, 2011 in the Notification of Compliance Status as specified in 40 CFR Section (b) For existing sources: q I am certifying below q I will certify by March 11, 2011 (There is no need to sign below, you must sign a statement by March 11, 2011) I certify the truth, accuracy, and completeness of this notification. The source has complied with all the relevant standards of this subpart. This initial notification also serves as the notification of compliance status. Signature of responsible official: owner / operator (circle one) Please Print Name Also 2

11 Submit Initial Notification as follows: a. To the appropriate Regional Office of the EPA (see addresses below); and b. If the State has been delegated the authority for this regulation under section 112(1) of the Clean Air Act, submit the notification to the appropriate State agency found at the following link: Addresses of EPA Regional Offices: EPA Region I (Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont), irector, Air, Pesticides and Toxics ivision, One Congress Street, Suite 1100 (SEA), Boston, MA 02114, Attn: Air Compliance Clerk. EPA Region II (New Jersey, New York, Puerto Rico, Virgin Islands), irector, Air and Waste Management ivision, 290 Broadway, New York, NY EPA Region III (elaware, istrict of Columbia, Maryland, Pennsylvania, Virginia, West Virginia), irector, Air Protection ivision, 1650 Arch Street, Philadelphia, PA EPA Region IV (Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee), irector, Air, Pesticides and Toxics Management ivision, Atlanta Federal Center, 61 Forsyth Street, Atlanta, GA EPA Region V (Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin), irector, Air and Radiation ivision, 77 West Jackson Blvd., Chicago, IL EPA Region VI (Arkansas, Louisiana, New Mexico, Oklahoma, Texas), irector, Air, Pesticides and Toxics, 1445 Ross Avenue, allas, TX EPA Region VII (Iowa, Kansas, Missouri, Nebraska), irector, Air, RCRA, and Toxics ivision, U.S. Environmental Protection Agency, 901 N. 5th Street, Kansas City, KS EPA Region VIII (Colorado, Montana, North akota, South akota, Utah, Wyoming), irector, Air and Toxics Technical Enforcement Program, Office of Enforcement, Compliance and Environmental Justice, 1595 Wynkoop Street, enver, CO EPA Region IX (Arizona, California, Hawaii, Nevada, American Samoa, Guam), irector, Air and Toxics ivision, 75 Hawthorne Street, San Francisco, CA EPA Region X (Alaska, Idaho, Oregon, Washington), irector, Office of Air, Waste and Toxics, th Ave., Suite 900, AWT-107, Seattle, WA

12 Training Requirements for The Paint Stripping and Miscellaneous Surface Coating Area Source Rule Subpart HHHHHH 40 CFR This is NOT an official EPA document. You can consult 73 FR 1738, pg. 1762, section (f) for more information. All painters who apply coatings at subject facilities must be certified that they have completed a training program that addresses the proper spray application of surface coatings and the proper setup and maintenance of spray equipment. After July 7, 2008, new employees at new sources have 180 days after hire to complete training. Employees at existing sources must complete by the compliance date (January 10, 2011) Refresher training, at least once every five years following initial training date is required Owners and operators who can show by documentation or certification that a painter's work experience and/or training has resulted in training equivalent to the training required are not required to provide the initial training to these painters. Owners or operators of subject facilities are required to maintain a list of all current personnel by name and job description who are required to be trained. The minimum requirements for training and certification are described below: 1. A description of the methods, such as testing, to be used at the completion of initial or refresher training to demonstrate, document, and provide certification of successful completion of the required training. 2. Hands-on and classroom instruction that addresses, at a minimum, the following the topics: a. Hands-on and classroom instruction on routine spray booth and filter maintenance, including filter selection and installation. b. Hands-on and classroom instruction on spray gun operation including: Spray gun equipment selection, Set up, and operation, Measuring coating viscosity, Selecting the proper fluid tip or nozzle, Achieving the proper spray pattern, Achieving the proper air pressure and volume, Achieving the proper fluid delivery rate. c. Hands-on and classroom instruction on spray technique including: Spray technique for different types of coatings to improve transfer efficiency and minimize coating usage and overspray, Maintaining the correct spray gun distance and angle to the part, Using proper banding and overlap, and reducing lead and lag spraying at the beginning and end of each stroke.

13 d. Classroom instruction on what is necessary for environmental compliance with the requirements of the NESHAP, Subpart HHHHHH, Paint Stripping and Miscellaneous Surface Coating for Area Sources Install/operate filter technology on all spray booths/stations/enclosures to achieve at least 98% capture efficiency. Spray booths/stations used to refinish complete motor vehicles or mobile equipment must be fully enclosed and ventilated at negative pressure or up to 0.05 inches water gauge positive pressure for booths that have seals on all doors and other openings and an automatic pressure balancing system. Spray booths/stations used to coat miscellaneous parts or products or vehicle subassemblies must have a full roof, at least three complete walls or side curtains, and ventilated so that air is drawn into the booth. Spray-applied coatings must be applied with a high volume, low pressure (HVLP) spray gun, electrostatic application, airless or air-assisted airless spray gun, or an approved equivalent technology. Paint spray gun cleaning must be done so that an atomized mist or spray of the cleaning solvent is not created outside a container that collects used gun cleaning solvent. Region 10 Regulatory Contact: Heather Valdez, , valdez.heather@epa.gov